A. Description of the Firm & Shareholders Tower View has been in operation since July 1999. The firm is currently SEC registered. Tower View is majority owned by Raman J Ghei, but also now has six minority stakeholders, none of which have ownership that exceeds 25%. For further details on our shareholders please contact us.
B. Types of Advisory Services Tower View is a fee-based investment adviser. Some of the services we offer to our clients include: managing investment portfolios for families, individuals, and companies, primarily personal, joint, custodial, trust and IRA accounts. We also have begun to offer Financial Planning services, also on a fee basis.
Tower View provides investment advisory services with respect to publicly traded securities, including stocks, bonds, exchange-traded funds (“ETFs”) cash and mutual funds.
Aside from advisory and planning services, Tower View also can offer advice related to expiration dates and the exercising of stock options, along with monitoring of positions held in restricted stock accounts.
In a small number of cases, Tower View has assumed an advisory, supervisory relationship with 529 providers. Tower View is the advisor of record and can receive duplicate statements, execute fund exchanges and assist the client with disbursing funds to their college of choice. These circumstances also could result in the client receiving a lower return from the 529 provider on their account as the firm will be charging a fee to assist with these 529 accounts. Tower View receives no compensation from any outside account provider, whether in the form of sales charges or shared fees.These accounts are included in our assets under management calculations.
C. Investment Management Advisory Services of Client Accounts With all clients we complete an Investment Policy Statement or Client Profile (or similar document) which outlines the general investment plans for the account(s). These plans are based upon the review of the information provided to us by the client. Including but not limited to clients age, Tower View Wealth Management- Form ADV Brochure - Part 2A4 | Page investment objective and time horizon for the investment. This evaluation is subjective in nature and can be broadly interpreted. The investment plan is communicated to the client in writing, and the client may respond, if they see fit, with any questions or concerns.
We do not as a matter of practice “re-balance” accounts when asset mixes or other similar asset class allocations change due to market conditions unless the variance is such that a more detailed review or discussion is warranted. If a client makes a large deposit or withdrawal, we will review the allocation and determine if material changes are warranted, and if so, communicate this to the client. We also limit changes to investment allocations if capital gains will be realized unless the client directs us to make the change or we feel that the client circumstances warrant such a change.
In addition, we do not as a matter of practice undertake “tax swaps” or loss harvesting unless the client specifically requests this action. We will however, as part of our ongoing review of portfolios, monitor gains/losses in taxable accounts and in certain circumstances not sell an entire position of a stock with a large gain, or defer the sale into the next tax year, or review if a suitable swap candidate exists for a position showing a loss.
We manage investment portfolios on both a discretionary and non-discretionary basis.
Non-discretionary portfolios are primarily limited to those 529 Plans and employer sponsored 401(k)s for which the client has asked us to assist with administration and review but over which we do not have discretionary powers nor the ability to facilitate trades or other account specific actions. For the purposes of our typical discretionary portfolio management service, Tower View has the discretion to determine without first obtaining client consent which and how many securities are to be purchased or sold in each account.
Clients may place reasonable restrictions upon the types of investments to be held in the portfolio, provided that such restrictions are clearly communicated in writing and Tower View maintains authority to accept or reject such restrictions.
Client portfolios are generally invested in one or more of several different model portfolios (such as Mutual Funds/ETFs, Stock Yield, Growth/Core, etc), but not every client will be invested in the entire model or at the same position weightings. These differences may be due to timing of the inception date of the relationship, available cash, the size

of the account, whether the account is managed on its own or as part of a household, and tax reasons. For more details on your particular account and or household and which model we are using and why we have selected it for you, please discuss with us directly.
It is common for portfolios to hold uninvested cash at times as positions are sold and the proceeds may not be immediately reinvested. In addition, if there are regular withdrawals from an account cash reserves will need to be maintained and if there is the likely need for larger ad hoc distributions, cash reserves will also need to be maintained. Cash reserves or their equivalents will likely impact portfolio returns and may generate no rate of return, and are included in fee calculations of assets under management.
As a result of the above factors, there has been and will likely continue to be significant variance in portfolio composition and performance between accounts, even if they have similar investment objectives.
In addition, it is not uncommon for clients to be invested in a combination of individual stocks, stock mutual funds/ETFs, bonds and bond mutual funds.
Tower View Wealth Management- Form ADV Brochure - Part 2A5 | Page Aside from the client circumstances discussed above which will ultimately drive the final mix of these investments, other mitigating circumstances might include, but are not limited to, client preferences, the time the client has been with Tower View, low cost basis securities, liquidity needs, taxes and time horizon.
We do not normally attempt to change investment mixes in response to changing market conditions, political situations or other macro or micro-economic events. We typically make changes to portfolios based upon our assessment of the attractiveness of the individual securities and/or funds we are invested in or considering for investment.
We periodically run weighting and exception reports in an effort to ensure all suitable clients are included in new investment ideas, but not every stock or fund is suitable for every client, and the ultimate determination is at our discretion. We use a best efforts approach to include all clients at targeted weightings, but these weightings will vary based upon account inception date, cash available, tax considerations and cash reserves for clients who regularly withdraw money.
Clients should understand there are inherent complexities in the investment of separately managed accounts for a very diverse client base and thus there will always exist wide variances in the composition of client portfolios.
D. Financial Planning Tower View offers Financial Planning services for individual Tower View Wealth Management Clients. This service is for clients who have general financial planning questions and may be seeking further guidance on topics such as retirement, budgeting, education funding, and outside retirement accounts. These plans and conversations are customized and based upon the needs of the individual Client.
All plans are based upon the information provided by the client, and it is the client’s responsibility to ensure that they have provided Tower View with current and accurate information to prepare an initial plan, and it is the client’s responsibility to inform the advisor of material changes to their financial situation for future updated plans. Clients who receive financial planning advice are under no obligation to act on our general consultation recommendations, and implementation is at their discretion. Clients should carefully consider and even consult with outside legal counsel, accountants or tax professionals regarding legal or tax implications of a particular recommendation or strategy as neither Tower View or its employees provide tax or legal advice, and our financial planning services are not intended to provide nor be interpreted as legal advice.
Clients should recognize that there is an inherent conflict of interest in our Financial Planning services, to the degree that for example, we may recommend a client increase their investment holdings (which would positively impact our fee income, should the client add to their investments under management with Tower View). Clients are under no obligation to follow our planning strategies or recommendations, or implement them through our services.
E. Wrap Fees Tower View does not currently participate in Wrap Fee programs.
F. Assets Under Management As of December 31, 2023, Tower View managed approximately $243,000,000 on a discretionary basis, and $162,700 on a non-discretionary basis.
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